If there’s one area that consistently connects food safety, regulatory compliance, and customer expectations—it’s product control. Over the years supporting sites through BRCGS audits, I’ve seen that most major issues—especially recalls—don’t happen because a food-safety plan failed. They happen because a label was wrong, an allergen was missed, or traceability broke down when it mattered.
That’s why Section 5 exists. It ensures that every ingredient, every process, every label, and every finished product is controlled—not loosely managed or assumed accurate.
By the time you finish this section, you’ll understand:
Exactly what BRC V9 expects for product specifications, allergen management, traceability, and release procedures.
How to build a system that’s audit-proof—not just audit-ready.
The mistakes that repeatedly lead to costly nonconformities and product withdrawals—and how to avoid them.
Clear, accurate, and controlled specifications are the backbone of product consistency. Under BRC V9, every product must have a documented and approved specification that defines:
Ingredients
Processing parameters
Allergen content
Microbiological or chemical limits (where relevant)
Labeling requirements
The key is control. Specifications aren’t “reference documents”—they’re operational instructions.
Where I see companies struggle is change management. Someone tweaks a formulation, and before anyone updates the label or spec sheet, the product is already in circulation. That’s how recalls happen.
A best practice is using a version-controlled approval process where R&D, Quality, Regulatory, and Production all sign off before the first batch is made. Slow? Maybe for a day. Safer long-term? Absolutely.
Supplier & Raw-Material Control — Testing, Verification & Risk Management
Every finished product is only as safe as the raw materials behind it. BRC V9 requires a documented system for approving and monitoring suppliers—not just assuming they’ll send compliant ingredients.
A strong raw-material control system should include:
Approved supplier list
COA/CofC verification
Sampling and testing (risk-based)
Annual performance review
I once watched a site fail an audit because a high-risk ingredient—ground spices—was accepted without allergen verification or documentation. The issue wasn’t the ingredient—it was the lack of proof.
Allergens are currently one of the leading causes of global food recalls, and BRC takes this seriously.
Allergen control requires:
Dedicated or segregated storage
Line scheduling to avoid contamination
Validated cleaning between runs
Double-check label approval process
Verification of final packaging accuracy
Where things often go wrong isn’t on the production floor—it’s in artwork updates, last-minute design edits, or miscommunication between departments.
One packaging change without review can cause a nationwide recall. That’s why BRC V9 expects a documented label verification system—not just a visual check.
Traceability & Mass Balance — Proving Control from Supplier to Customer
Traceability isn’t just a theoretical exercise—it needs to work under pressure.
Auditors will test whether you can trace:
Raw materials from supplier to batch
WIP through the facility
Finished product to customers
Packaging to product
And they’ll expect a successful mass-balance within a set time—commonly four hours, though best-performing sites complete it in under one.
Digital traceability systems help—but only when used consistently. Manual systems are fine too, as long as records are accurate, legible, and linked logically.
A good benchmark: if a new employee can’t follow your traceability flow, it’s too complicated.
Under BRC V9, “looks okay” is not a release strategy.
Release must be based on:
Finished-product test results (where applicable)
CCP verification
Packaging and label checks
Shelf-life validation
Shelf-life must be scientifically supported—not assumed based on competitors or tradition.
A mistake I see often: releasing product before test results return, especially in fast-moving facilities. If a test is part of release criteria, product must not ship until review is documented.
It’s not about slowing production—it’s about controlling risk.
Product Authenticity, Food Fraud & Compliance with Regulatory Claims
Product integrity goes beyond safety. BRC expects proof that what you claim is true.
This includes:
Country-of-origin claims
Organic, halal, kosher, non-GMO certifications
Ingredient authenticity for high-risk products like honey, coffee, oils, spices, seafood
Food-fraud vulnerability assessments must be updated annually—or sooner if global risk changes.
If you make a claim, you must be able to back it up confidently.
Product Preservation, Handling & Storage — Protecting Quality Until Shipment
From production to dispatch, product control continues.
Requirements include:
FIFO/FEFO stock rotation
Controlled temperatures
Handling procedures
Clear labeling of work-in-progress and finished goods
A common issue: alarm systems functioning—but no documented corrective action when temperatures exceed limits.
Auditors don’t just want to see alarms—they want to see how you responded.
FAQs
Q: Do all sites need allergen validation testing, even if they don’t handle allergens? Yes—at minimum, a documented risk assessment is required to confirm the status.
Q: Is digital traceability required for BRC V9? Not mandatory—but digital systems improve accuracy and speed, especially during audits.
Q: How often should specifications be reviewed? At least annually—or sooner if formulation, supplier, process, or regulation changes.
Conclusion — Strong Product Control Prevents Recalls Before They Happen
Product control is about consistency, accuracy, and proof. When specifications are current, allergens are controlled, traceability is fast, and product release is based on evidence—not assumption—you protect your customers and your brand.
If you’d like downloadable templates for traceability testing, allergen verification, or product-specification forms aligned to BRC V9, that’s the next easy step.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
